Financial institutions routinely open accounts for consumers and businesses and the rules for providing account disclosures, account agreements, and signature cards are well established. However, the legal and compliance issues involved with closing accounts are often more complicated. Why? Because there are wide-ranging situations, including accountholder death, suspected fraud or money laundering, disputes between account owners, and requests to levy funds. This session will address two focal areas. First will be the challenges of closing or changing consumer accounts. Second will be specific complexities regarding various ownership categories of business accounts.
- Consumer account basics
- Joint accountholder issues – who has authority to change and close an account?
- Best practices for changing signers and signature card basics
- Handling checks made payable to a deceased person
- BSA issues
- Closing an account for failing to provide required CIP documentation
- Closing an account for suspicious activity (FinCEN guidance and working with law enforcement)
- Best practices for closing consumer and business accounts and related BSA exam procedures
- Business account basics
- CIP rules for business accounts
- Opening, changing, and closing sole proprietor, partnership, LLC, and corporate accounts
- New rules for beneficial ownership began May 11, 2018, and apply to legal entity customers
- Death of a business owner and types of business ownership categories
- TAKE-AWAY TOOLKIT
- Account owner/authorized signer information worksheet
- New account checklist
- Checklist for CIP acceptable identification
- Federal garnishment notice form
- Account closure form letter
- Employee training log
- Quiz you can administer to measure staff learning and a separate answer key
WHO SHOULD ATTEND?
This informative session is designed for new accounts representatives, call service representatives, branch managers, assistant branch managers, branch administration, deposit operations, BSA/CIP staff, and anyone who works with new accounts.
SPEAKER: Susan Costonis, Compliance Consulting and Training for Financial Institutions
Susan Costonis is a compliance consultant and trainer. She specializes in compliance management along with deposit and lending regulatory training. Most of her 35-year career was spent as a banker in several areas including lending, loan administration, electronic banking, and compliance risk management.
Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve. Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real-life examples.